Legal
Last updated: March 24, 2026
MANA³ is a practitioner-facing coherence and performance tracking platform operated by Maxime Fréchet, based in Geneva, Switzerland. We process health and wellness data on behalf of practitioners and their clients to generate longitudinal coherence reports.
Data Controller: Maxime Fréchet, MANA³
Contact: maxime-frechet@mana-cubed.com
Location: Geneva, Switzerland
We collect and process data from three sources, corresponding to our three-tier data architecture. The data we collect falls into the following categories:
| Data Source | Data Types | Collection Method |
|---|---|---|
| Wearable devices (Garmin, Polar, Oura) |
Sleep scores, heart rate variability (HRV), resting heart rate, stress levels, Body Battery / readiness scores, training load, VO2max estimates, activity data, step count | Automated sync via device manufacturer APIs (Garmin Health API, Polar AccessLink API, Oura API). Data is pushed or pulled from the manufacturer's servers with the client's explicit authorization. |
| Practitioner assessments | Postural analysis scores, movement screening results, clinical observations, body composition measurements, practitioner notes | Entered manually by the practitioner during scheduled assessment sessions. |
| Client check-ins | Daily subjective ratings for energy, mood, soreness, sleep quality, stress perception, motivation, and recovery | Submitted daily by the client via a digital form (Typeform). |
| Account information | Name, email address, date of birth, device type, practitioner assignment | Provided by the client or practitioner during onboarding. |
We process personal and health data for the following purposes:
Coherence tracking and reporting: To generate longitudinal coherence reports that track how a client's physiological systems interact and evolve over time. This is the core service provided by MANA³.
Practitioner intelligence: To provide practitioners with data-driven insights that support their clinical decision-making in guiding clients toward their health, performance, and longevity goals.
Platform operation: To maintain client accounts, synchronize wearable data, process daily check-ins, and deliver reports.
Under the EU General Data Protection Regulation (GDPR) and the Swiss Federal Act on Data Protection (nFADP), we process your data on the following legal bases:
Explicit consent (Art. 9(2)(a) GDPR): Health data is classified as a special category of personal data. We process this data only with the client's explicit, informed consent, obtained during onboarding. This consent covers the collection of wearable device data, practitioner assessment data, and daily check-in data.
Contractual necessity (Art. 6(1)(b) GDPR): Processing of account information is necessary to provide the MANA³ service as agreed between the practitioner, client, and platform.
MANA³ integrates with wearable device platforms including Garmin (via the Garmin Health API), Polar (via the Polar AccessLink API), and Oura (via the Oura API) to collect wellness and activity data.
When a client connects their wearable device to MANA³, they authorize the device manufacturer to share their data with our platform. This authorization can be revoked at any time through the device manufacturer's settings or by contacting us directly.
We do not sell, share, or transfer wearable device data to any third party. Data received from wearable device APIs is used exclusively for generating coherence reports within the MANA³ platform and is accessible only to the client and their assigned practitioner.
We do not store raw API responses beyond what is necessary to compute coherence scores. Processed data is stored as normalized anchor values (sleep score, readiness score, stress proxy) without retaining the full device data payload.
Client data is stored in a secure database with access restricted to the assigned practitioner and the MANA³ platform. We implement the following security measures:
Access control: Each client's data is accessible only to their assigned practitioner and to the MANA³ system for report generation. No other practitioners, clients, or third parties can access the data.
Encryption: Data is encrypted in transit (TLS/SSL) and at rest where supported by the hosting infrastructure.
Data minimization: We collect only the data necessary to generate coherence reports. We do not collect GPS location data, social data, or any data beyond what is described in Section 2.
Access to your data is strictly limited to:
Your assigned practitioner: The practitioner you have been paired with through the MANA³ platform. They access your data to provide personalized guidance.
The MANA³ platform: Automated systems that process your data to generate coherence scores and reports. This includes an AI-assisted narrative engine that produces interpretive summaries of your data for your practitioner.
We do not share your data with advertisers, data brokers, research institutions, or any other third party. We do not use your data for any purpose other than delivering the MANA³ service.
We retain your data for as long as you are an active client on the platform. If you or your practitioner terminate the service, we will delete your personal and health data within 30 days of receiving a deletion request, unless we are legally required to retain it for a longer period.
Anonymized, aggregated data that cannot be traced back to any individual may be retained for the purpose of improving the platform's coherence models.
Under the GDPR and Swiss nFADP, you have the following rights regarding your personal data:
Right of access: You can request a copy of all personal data we hold about you.
Right to rectification: You can request correction of inaccurate data.
Right to erasure: You can request deletion of your data at any time. This includes revocation of wearable device authorization.
Right to data portability: You can request your data in a structured, commonly used, machine-readable format.
Right to withdraw consent: You can withdraw your consent to data processing at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.
Right to lodge a complaint: You have the right to lodge a complaint with a supervisory authority. For EU residents, this is the relevant Data Protection Authority in your member state. For Swiss residents, this is the Federal Data Protection and Information Commissioner (FDPIC).
To exercise any of these rights, contact us at the address below.
MANA³ operates from Switzerland, which benefits from an EU adequacy decision for data protection. When wearable device data is transferred from device manufacturers (who may store data outside Switzerland or the EU), this transfer is governed by the data processing agreements between the client and the device manufacturer (e.g., Garmin, Polar, Oura) and their respective privacy policies.
We may update this privacy policy from time to time to reflect changes in our practices or legal requirements. Any significant changes will be communicated to active clients and their practitioners. The date at the top of this page indicates when the policy was last updated.
For any questions, concerns, or requests related to this privacy policy or the processing of your personal data, please contact: